A major bank lender to DECA Financial Services says the company’s founder and owner Todd Wolfe falsified a key document he submitted in his lawsuit against the bank.

Wolfe “engaged in a massive fraud upon the bank and this court,” BMO Harris Bank says regarding a document he filed in Hamilton County Superior Court that says his living trust has $14 million in an account at John Hancock Life Insurance Co.

In fact, Wolfe’s trust contains just $13,433, the bank said.

Wolfe, who founded DECA in 2010, said in an email that the allegation is the latest of “numerous untrue and outrageous representations disparaging me to the court.”

The bank filed a motion for sanctions against Wolfe last week that asks the court to dismiss Wolfe’s breach-of-contract lawsuit and enter a judgment in favor of the bank on its counterclaims.

Wolfe had submitted the document to the court as part of his lawsuit against the bank, which last year froze his and DECA’s bank accounts after the bank said DECA defaulted on $10 million in loans. Wolfe submitted the insurance document to show the court that he has funds to pay off the bank.

The sanctions filing comes as DECA, a Fishers debt collection agency, is in the end stages of liquidation. Just two years ago it was one of the fastest growing companies in the state.

BMO Harris, represented by the Indianapolis firm of Krieg DeVault, filed an affidavit from Massachusetts-based John Hancock saying that the insurer does not have an account for the Todd J. Wolfe Living Trust and that the document given to the court does not exist in records at the insurance company.

“The funds which the plaintiffs have repeatedly promised to pay the bank do not exist,” the bank’s motion says. It asks the court to sanction Wolfe for “reprehensible conduct that includes committing perjury, discovery violations, manufacturing evidence and violating orders of this court.”

Wolfe said it wouldn’t make sense for him to falsify the document. “Why would I represent assets that do not exist when it only harms me in legal costs to defend these ‘phantom assets?’ ” he said in an emailed statement.

“The only people that have been proven to have been untruthful is the defendant BMO and several individuals that have testified on their behalf,” Wolfe said. “I am confident that the passage of time will show this most recent filing to just be more of the same and hope that in the end both BMO and Krieg DeVault learn from this case and do not continue such abusive practices.”

DECA was put into involuntary bankruptcy earlier this year by creditors, who persuaded a bankruptcy court judge to appoint a trustee to take over running the company from Wolfe. In April, the judge approved a motion to wind down operations of DECA. The collections company once was lauded for its fast growth by Inc. magazine and won accolades from state officials as well as state economic incentives in 2012 for a headquarters expansion.

DECA is known to thousands of Indiana consumers for its aggressive debt-collection practices that include suing consumers in county courts for sums as small as a few hundred dollars.